Securing the Nation’s Wastewater Infrastructure
As part of a 1998 presidential directive, the federal government began to assess the vulnerability of U.S. infrastructure and develop ways to protect it. After the September 11 attacks, these assessments became an even greater national priority.
The 1998 directive identified several categories as critical: aviation, highways and mass transit; pipelines, rail and waterborne commerce; public health services; electric power; oil and gas production and storage; information and communications; banking and finance; and the drinking water supply.
Absent from the list was the nation’s wastewater infrastructure—16,000 publicly-owned wastewater treatment plants (POTWs), 100,000 key pumping stations and 600,000 miles of sanitary sewer lines.
To the average person, safeguarding wastewater utilities may seem less urgent, but in many ways it’s just as important. In fact, the nation’s wastewater infrastructure is one of America’s most valuable assets, worth more than $2 trillion—a fact not lost on potential terrorists.
If someone were to introduce enough flammable or explosive materials into a wastewater collection system, the resulting fire and/or explosion could be lethal, causing significant damage to the wastewater infrastructure and its surrounding environment.
And what if a terrorist were to sabotage wastewater treatment equipment? High levels of toxins could potentially contaminate the local water quality and pollute downstream drinking supplies.
“With regard to wastewater systems, proximity or access to critical buildings is the main problem. Sewers that run beneath or near airports, critical structures, or federal facilities could allow explosives or other energetics or combustibles to be detonated close enough to create mass destruction,” environmental engineer Richard Lancaster-Brooks stated in the Journal of Homeland Security.
“Wastewater utilities need to implement many of the same security measures as water treatment facilities in terms of securing their premises and preparing for emergency response,” he advised, adding several wastewater-specific measures:
- Inventory critical wastewater and stormwater equipment, evaluating how close they are to high-risk locations;
- Install tamperproof manholes and sensors in sewer and stormsewer lines in high-risk areas;
- Monitor all chemicals that are stored on-site;
- Establish alarm levels that trigger an investigative or emergency response for all of the monitored parameters; and
- Monitor pH, corrosivity, oxidation-reduction, flammability and air within the collection system for explosivity, and monitor total chlorine residual at the outfall as recommended by the EPA.
Feds urge continued vigilance
As recently as mid-August, federal officials distributed a general bulletin urging municipalities nationwide to verify that effective security measures are in place at their water and wastewater treatment plants—and being strictly adhered to by employees.
The bulletin was issued Aug. 11 by the U.S. Department of Homeland Security and the Federal Bureau of Investigation. It was then distributed to local Emergency Management Agency (EMA) offices, as well as through the Water Information Sharing and Analysis Center. County EMA offices then notified communities with treatment facilities to review their security systems and continue to be vigilant.
The federal agencies had “no information that identifies a current credible threat” to U.S. drinking water and wastewater treatment plants. Yet these facilities may be vulnerable to “insider terrorist threats that could be both physical and cyber in nature.”
The agencies issued the warning after reviewing information that prior to Sept. 11, 2001, terrorists had discussed ways to poison U.S. water supplies. However, they gleaned no information about specific targets or how far along operatives might have been in carrying out such plots after 9/11.
Nonetheless, the bulletin warned, it is quite plausible to believe the water contamination plot “could be revisited by terrorists … (We) further assess that information discussed by the terrorists exhibits a certain degree of operations sophistication and is of particular concern for largely unattended drinking water or wastewater treatment facilities.”
Of all the various ways drinking water could be contaminated, noted the agencies, the misuse of hazardous chemicals is of particular concern.
To reduce this risk, the agencies stressed the critical importance of continuing to take extra precautions to ensure security. These include conducting thorough employee background checks, forbidding unescorted plant access by former employees, scrutinizing actions of contractors and vendors, verifying all chemical deliveries and adhering to cyber security standards.
EPA leads the way
As the lead agency in charge of securing the wastewater sector, EPA works closely with the Water Environment Federation (WEF) and the Association of Metropolitan Sewerage Agencies (AMSA) to ensure protective measures are identified and implemented.
Last month, EPA allocated $1 million in FY 2004 funding to its Regions for grants to established state environmental training centers to increase security among small and medium-sized wastewater systems. With this funding, state environmental training centers will be equipped to provide on-site operator training assistance or classroom training on the use of vulnerability assessment tools, emergency response plan development and upgrades, and security system upgrades.
Back in February, EPA’s National Drinking Water Advisory Council (NDWAC) formed the Water Security Working Group (WSWG) to address best security practices for drinking water and wastewater facilities, and help them develop methods to increase security against malevolent efforts.
The group held its first teleconference meeting, open to the public, on July 6. It provided a forum for the WSWG members to discuss the group’s ground rules and standard operating procedures; develop an estimated time frame and approach to complete the WSWG’s objectives; and hear from citizens about their concerns.
The WSWG has been put in charge of providing recommendations to the full NDWAC. The group’s mission is to:
- Identify, compile and characterize best security practices and policies for drinking water and wastewater utilities, and provide an approach for considering and adopting these practices and policies at a utility level;
- Consider mechanisms to provide recognition and incentives that facilitate a broad and receptive response among the water sector to implement these best security practices and policies and make recommendations as appropriate; and
- Consider mechanisms to measure the extent of implementation of these best security practices and policies, identify the impediments of their implementation, and make recommendations as appropriate. Several more meetings will be held through next spring, about every other month. The WSWG plans to submit its final recommendations to the full NDWAC council in May 2005. Later in the year, NDWAC will in turn make appropriate recommendations to EPA.
WEF provides training
Although POTWs are not under statutory deadlines to conduct vulnerability assessments and submit them to EPA—such as the nation’s community water systems have done—such appraisals are highly recommended.
Through a cooperative agreement with EPA, WEF has offered its innovative security training program nationwide for several years, teaching wastewater utility workers how to evaluate their facilities and then determine methods that would reduce vulnerability to man-made threats and natural disasters.
Building on a previous training events attended by hundreds from the nation’s largest POTWs, this year’s training program was developed for small/medium POTWs treating 5–15 mgd. It consists of ten regional workshops designed to guide each utility through the steps of conducting a vulnerability assessment (VA) and creating an emergency response plan (ERP).
Experts who designed the Vulnerability Self Assessment Tool (VSAT™) software, specifically designed for wastewater utilities, are there to train POTW managers and operators how to use it. Included in this analytical tool are reference libraries of potential threats and countermeasures, as well as a method for managing the information gained through VAs.
POTW staff members come prepared with data from their plants. After arriving at a baseline VA and security improvement analysis, VSAT calculates “Risk Reduction Units” for various countermeasures, as well as their costs, to arrive at a cost per risk reduction unit. At the end of the analysis, managers use VSAT to directly support decisions on the most cost-effective approach to security improvements. The software compiles cost and risk profiles for scenarios with various combinations of countermeasures—documenting all decisions and assumptions so managers can track and validate their decision process. It can be updated as assets, threats or countermeasures change. Although most of this year’s workshops already have taken place, two more are coming up soon:
• New Orleans, La. (WEFTEC ’04) — Oct. 6–7,
• Tucson, Ariz. — Oct. 21–22
In addition to conducting workshops themselves, WEF provides training and resource kits to state environmental assistance providers who offer training to small and rural POTWs. More than 150 wastewater security professionals attended WEF’s “train the trainer” program. They went on to provide free to low-cost training for small and rural POTWs.
“WEF and EPA agreed to offer these workshops at no-cost to the POTW community as a proactive approach to raise awareness of security issues at POTWs, and to assist managers and operators make decisions on implementing countermeasures in the most efficient way possible,” according to WEF’s website (www.wef.org).
Along with WEF, AMSA also is very much involved in wastewater security initiatives. With funding from EPA, the VSAT line of software used by WEF in its training workshops was developed by AMSA in collaboration with PA Consulting Group and Scientech, Inc.
AMSA recently received a $147,000 grant to develop a “Decontamination Wastewater Acceptance and Treatment Planning Tool” that would provide a general protocol for POTWs when handling wastewater contaminated with chemical, biological or radiological agents following a large-scale terrorist attack. POTWs will be able to customize the Planning Tool to address specific contaminants. Earlier this year, EPA awarded a grant of $400,000 to help AMSA continue to enhance its suite of VSAT software. These enhancements will include a more streamlined version of the tool’s report functions, an emergency response plan function, increased data manipulation speeds, improved presentation graphics, and an update of the countermeasure libraries.
Wastewater Treatment Works Security Act
In the 107th Congress, as part of the Public Health Security and Bioterrorism Preparedness Act, Congress authorized $160 million to conduct vulnerability assessments at drinking water facilities. As for analyzing wastewater-related threats, the House passed a similar measure (H.R. 5169), however the Senate did not take up the measure before adjournment.
Both the House and Senate introduced companion wastewater security bills in 2003 in the 108th Congress. Senate Environment & Public Works (EPW) Committee Chairman James Inhofe introduced S. 1039, the “Wastewater Treatment Works Security Act of 2003.” Congressman Don Young, chairman of the House Transportation and Infrastructure Committee, introduced H.R. 866, which serves as the House version of the Wastewater Treatment Works Security Act. First it passed the House T&I Committee and later passed the full House by a vote of 413-2.
Both bills propose providing $200 million in grants to states, municipalities and inter-municipal/interstate agencies to conduct vulnerability assessments of POTWs and further enhance security. Additionally, the bills would authorize $15 million for technical aid to small POTWs serving communities of 20,000 or fewer residents.
As for the current status, the National Society of Professional Engineers, which supports both bills, stated its view in a May 2004 issue brief:
“S. 1039 and H.R. 866 at this point are very similar and it is possible they could be reconciled informally without a conference committee being held. It is too early to tell whether this could happen since the Senate still has the opportunity to amend the measure on the floor.”